Recommended Practices for Safety and Health Programs in Construction

RECOMMENDED WORK
PRACTICES FOR SAFETY
AND HEALTH IN
CONSTRUCTION
Bernard L. Fontaine, Jr., CIH, CSP, FAIHA
The Windsor Consulting Group, Inc.
14 Sheinfine Avenue
South River, NJ 08882
TEL: 1+ 732.221.5687
“Protecting Workers for Over 40 Years”

•Top management demonstrates its commitment to
eliminating hazards, continuously improve
workplace safety and health, communicates that
commitment to workers, and sets management
program expectations and responsibilities.
•Managers at all levels make safety and health a
core organizational value, establish safety and
health goals and objectives, provide adequate
resources and support for the program, and set a
good example.
Management Leadership

•Establish a written policy signed by top
management describing the organization’s
commitment to safety and health, and pledging
to establish and maintain a safety and health
program for all workers.
•Communicate the policy to all workers and, at
appropriate times and places, to relevant parties,
including: contractors, subcontractors, staffing
agencies, and temporary workers at your
worksite(s); suppliers and vendors; tenants in a
multi-tenant building; visitors and guests, etc.

•Reinforce management commitment by considering
safety and health in all business decisions, including
estimating and bidding on projects, subcontractor
and vendor selection, scheduling, and implementing
safety designs into construction processes,
drawings, and modifications.
•Be visible in operations and set an example by
following the same safety and health procedures
you expect workers to follow.
•Conduct weekly or daily toolbox talks on safety and
health, and discuss/review safety and health
indicators and/or open safety items on a “to do” list.

•Establish realistic, measurable goals for improving
safety and health.
•Develop plans to achieve the goals by assigning
tasks and responsibilities to particular people,
setting timeframes, and determining resources.
•Estimate the resources needed to establish
and implement the program. One example is
ensuring safety equipment is included in the
project budget.
•Allow time in workers’ schedules for them to fully
participate in the program. Safety can be built
into the labor rates when estimating a project.

•Integrate safety and health into planning and
budget processes, and align it with program needs.
•Provide and direct resources to operate and
maintain the program, meet safety and health
commitments, and pursue program goals.
•Identify frontline person or persons who will lead
the safety program effort, make plans, coordinate
activities, and track progress.
•Define and regularly communicate responsibilities
and authorities for implementing and maintaining
the program, and hold people accountable for
performance.

•Provide positive recognition for meeting or
exceeding safety and health goals aimed at
preventing injury and illness (e.g., reporting near
misses, attending training, conducting inspections).
•Establish ways for management and all workers
to communicate freely and often about safety
and health issues, without fear of retaliation.

•Workers and their representatives get involved in all
aspects of the program—including goal setting,
identifying and reporting hazards, investigating
incidents, and tracking progress.
•All workers, including contractors and temporary
workers, understanding roles and responsibilities
under the program and what they need to do to
effectively carry them out.
•Workers are encouraged to communicate openly
with management and to report safety and health
concerns or suggest improvements, without fear of
retaliation.
Worker Participation

•Any potential barriers or obstacles to worker
participation in the program (for example,
language, lack of information, or disincentives) are
removed or addressed.
•Give workers the necessary time and
resources to participate in the program.
•Acknowledge and provide positive reinforcement
to those who participate in the program.
•Maintain open door policy that invites workers to
talk to managers about safety and health and to
make suggestions.

•Establish a simple process for workers to report
injuries, illnesses, near misses, hazards, and other
safety and health concerns, and respond to reports
promptly.
•Include an option for anonymous reporting to
reduce fear of reprisal.
•Report back to workers routinely and frequently
about action taken in response to their concerns
and suggestions.
•Emphasize that management will use reported
information only to improve job site safety
and health.

•Empower all workers to initiate or request a
temporary suspension or shutdown of any work
activity or operation they believe to be unsafe.
•Involve workers in finding solutions to
reported issues.
•Give workers information they need to understand
safety and health hazards and control measures on
the job site. Some OSHA standards require
employers to make specific types of information
available to workers, such as: SDS, recordable
injuries and illness, exposure monitoring, chemical
and equipment manufacturer recommendations, etc.

•Provide opportunities for workers to participate in
all aspects of the program, including, but not limited
to helping: develop the program and set goals,
report hazards and develop solutions, analyze work
hazards, define safe work practices and operating
procedures, train co-workers and new hires, and the
evaluate program performance.
•Ensure workers from all levels of the organization
can participate regardless of their skill level,
education, or language.
•Provide frequent and regular feedback to show
employees are heard and issues are addressed.

•Authorize sufficient time and resources to allow
worker participation; for example, hold safety and
health meetings during regular working hours.
•Ensure the program protects workers from being
retaliated against for reporting injuries, illnesses,
and hazards; participating in the program; or
exercising their safety and health rights.
•Ensure that other policies and programs do not
discourage worker participation.

•Procedures are put in place to continually identify
workplace hazards and evaluate risks.
•Safety and health hazards from routine, nonroutine,
and emergencies are identified and assessed.
•Initial assessment of existing hazards, exposures,
risk and control measures, followed by periodic
inspections and reassessments, to identify any new
hazards.
•Any incidents are investigated with the goal of
identifying the root causes.
•Identified hazards are prioritized for control.
Hazard Identification and
Risk Assessment

•In construction, unanticipated hazards can arise
due to changes in project timelines, sequence of
events, and the fast pace of some construction
projects.
•Hazard identification and assessment is a crucial
part of an effective safety and health program.
•Collect and review information about the
hazards present or likely to be present at job site.
•Conduct frequent and regular inspections of
the job site to identify new or recurring hazards.
•Group similar incidents and identify trends in
injuries, illnesses, and hazards reported.
Risk Assessment

•Investigate injuries, illnesses, incidents, and close
calls/near misses to identify the underlying hazards,
their causes, and safety and health program and
procedural shortcomings.
•Consider hazards associated with emergency
or nonroutine situations.
•For each hazard identified, determine both the
severity and likelihood of incidents that could
result, and use information to prioritize corrective
actions.
Risk Assessment

•Information on types of hazards may be found in
various internal places, such as:
 Equipment and machinery operating manuals
 SDSs provided by the chemical manufacturer
 Self-inspection reports and loss control
reports from insurance carriers
 Records of previous injuries and illnesses
 Exposure monitoring results or industrial
hygiene assessments
 Input from workers or minutes from safety and
health committee meetings
 Results of job hazard analyses
Risk Assessment

•Information on types of hazards may be found in
various external places, such as:
 OSHA, National Institute for Occupational
Safety and Health (NIOSH), and Centers for
Disease Control and Prevention (CDC)
websites, publications, and alerts
 Trade associations and safety and health
professional associations
 Labor unions, state safety and health
committees, and worker advocacy group
 Safety and health consultants
Risk Assessment

•Designate a competent person(s) to conduct
frequent and regular inspections of the job sites,
materials, and equipment.
•Plan ahead to anticipate additional hazards by the
next group of trades or sequence of construction
activities and address these additional hazards.
•Document inspections to verify that hazardous
conditions have been corrected.
•Take photos or video of problem areas to facilitate
on-the-job discussion and brainstorm about how to
implement controls.
Risk Assessment

•Include all areas and activities in these inspections,
such as trenching and excavations, staging areas,
layout yards, working at heights, materials storage,
heavy equipment maintenance, training, and work
activities of on-site contractors, subcontractors, and
temporary workers.
•Regularly inspect construction equipment (e.g.,
forklifts, bulldozers, aerial lifts and cranes) and job
site transportation vehicles (e.g., cars, trucks).
•Create material delivery areas and internal
traffic control plans for the construction site
and laydown areas.
Risk Assessment

•Use checklists that highlight things to look for like:
 Slip, trip, and fall hazards
 Electrical hazards
 General housekeeping
 Equipment operation
 Equipment maintenance
 Fire protection
 Work organization and process flow
 Work practices
 Ergonomic problems
 Emergency procedures
 Training and education
Risk Assessment

•Identify chemical hazards by reviewing SDSs and
product labels to identify chemicals at the job site
that have low exposure limits, highly volatile, used in
large quantities or in unventilated spaces.
•Identify work activities that may result in ingestion
or skin exposure to chemicals.
•Identify physical hazards and exposure to loud
noise, elevated hot or cold temperatures, sources of
ionizing radiation (radioactive materials or X-rays),
or nonionizing radiofrequency or electromagnetic
radiation sources (arc welding, telecommunication
or television towers, and high voltage electricity).
Risk Assessment

•Identify biological hazards and exposure to sources
of infectious diseases, molds, toxic or poisonous
plants, or animal materials (urine or dung) capable
of causing allergic reactions or asthma.
•Identify ergonomic risk factors by examining work
activities that require heavy lifting, work above
shoulder height, repetitive motions, or tasks with
significant vibration.
•Conduct quantitative exposure risk assessments,
using air sampling or direct reading instruments.
•Review OSHA 300 logs to identify health and safety
hazards associated with job site exposures.
Risk Assessment

•Incidents—including injuries, illnesses, close
calls/near misses, and reports of other concerns—
provide a clear indication of where hazards exist. By
thoroughly investigating incidents and reports, you
will identify hazards that are likely to cause future
harm.
•Investigation must always be to identify the root
causes of the incident or concern, to prevent future
occurrences.
•Develop a clear plan and procedure to conduct an
immediate incident investigation of any mishap or
near-miss incident.
Risk Assessment

•Emergencies present for routine job site hazards
need to be clearly recognized and well understood.
•Nonroutine or infrequent tasks include: mobilization
and demobilization, fires, critical lifts with cranes,
concrete pours, weather, setting critical structural
members or structural collapse, chemical spills or
release, medical issues also may present hazards.
•Plans and procedures need to be developed for
responding appropriately to health and safety
hazards associated with foreseeable emergency
scenarios and nonroutine situations.
Risk Assessment

•Next step is to assess and understand the hazards
identified and the types of incidents that could result
unacceptable risk to exposed worker to the hazards.
•Information can be used to develop interim risk
management solutions and to prioritize hazards for
permanent control.
•Evaluate the hazard by considering the severity of
the outcome and likelihood for an event or exposure
to occur, and number of at-risk workers exposed.
•Use interim control measures to protect workers
until a permanent solution can be implemented.
•Prioritize safety and health hazards of greatest risk.
Risk Assessment

•Employers and workers cooperate to identify and
select methods for eliminating, preventing,
or controlling workplace hazards.
•Controls are selected according to a hierarchy that
uses engineering solutions first, followed by
safe work practices, administrative controls, and
finally personal protective equipment (PPE).
•Develop a plan to ensure control are implemented,
interim protection is provided, progress is tracked,
and the effectiveness of controls is verified.
•Effective controls protect workers from hazards;
avoid injuries and illnesses, and minimize risk.
Hazard Prevention and
Control

•Hazard prevention and control involves workers,
who often have best understanding of the conditions
that create hazards and insights for control.
•Identify and evaluate options to control hazards,
using a “hierarchy of controls.”
•Use a hazard control plan to guide selection and
implementation according to a defined plan.
•Develop plans with measures to protect workers
during emergencies and nonroutine activities.
•Evaluate effectiveness of existing controls to
determine if they continue to provide protection, or
whether different controls may be more effective.
Control

•Review new technologies for their potential to be
more protective, more reliable, or less costly.
•Review sources such as OSHA standards
and guidance, industry consensus standards,
NIOSH publications, manufacturers’ literature,
and engineering reports to identify potential
control measures.
•Keep current on relevant information from trade or
professional associations.
•Investigate control measures used on projects to
determine relevance and effectiveness at other job
sites.
Control

•Collaborate with workers able to suggest and
evaluate solutions based on their knowledge of the
job site, equipment, and work processes.
•For more complex hazards, consult with certified
safety and health experts, including OSHA’s On-site
Consultation Program.
•Experts are those are Certified Industrial Hygienists
(CIHs) by the American Board of Industrial Hygiene
and Certified Safety Professionals (CSPs) by the
Board of Certified Safety Professionals.
•Employers should select the controls that are the
most feasible, effective, and permanent.
Control

•Eliminate or control all serious hazards that are
causing or are likely to cause death or serious
physical harm immediately.
•Use interim controls while developing plans to
implement longer-term solutions.
•Select controls according to a hierarchy that
emphasizes engineering solutions (including
elimination or substitution) followed by safe work
practices, administrative controls, and finally PPE.
•Avoid selecting controls that may directly or
indirectly introduce new hazards like exhausting
contaminated air into occupied work spaces.
Control

•Review and discuss control options with workers to
ensure that controls are feasible and effective.
•Use a combination of controls when no single
method fully protects workers.
•Develop or update a hazard control plan that
describes how selected control measures will be
implemented.
•List hazards needing controls in order of priority.
•Assign responsibility for installing/implementing the
controls to a specific person or persons with the
power or ability to implement the controls.
•Establish a target completion date.
Control

•Plan how to track progress toward completion.
•Plan how to verify the effectiveness of controls after
they are installed or implemented.
•A hazard control plan includes provisions to protect
workers during nonroutine tasks and foreseeable
Emergencies.
•Procure equipment needed to control emergency-
related hazards.
•Assign responsibilities to implement the plan.
•Conduct emergency drills to ensure procedures
and equipment provide adequate protection during
emergency situations.
Control

•All workers are trained to understand how the
program works and how to carry out the
responsibilities assigned to them under the
program.
•Employers, managers, and supervisors receive
training on safety concepts and their responsibility
for protecting workers’ rights and responding to
workers’ reports and concerns.
•All workers are trained to recognize workplace
hazards and to understand the control measures
that have been implemented.
Education and Training

•Employers (owners and executives), managers,
supervisors, and workers should receive:
 Knowledge and skills needed to do their work
safely and avoid creating hazards that could
place themselves or others at risk.
 Awareness and understanding of hazards and
how to identify, report, and control them.
 Specialized training, when their work involves
unique hazards.
 Leadership and mishap incident investigation
training and education.

•Effective training and education can be provided
both inside and outside a formal classroom setting. •
•Examples include peer-to-peer training, on-the-job
training, daily toolbox talks, worksite demonstrations
and handouts can be effective in conveying safety
concepts, ensuring understanding of hazards and
their controls, and promoting good work practices.
•Managers, supervisors, and workers all need to
understand the safety and health policies, goals,
and procedures.

•Provide training to all managers; supervisors;
workers; and contractor, subcontractor, and
temporary agency workers on:
 Safety and health policies, goals, and
procedures
 Functions of the safety and health program
 Whom to contact with questions or concerns
 How to report hazards, injuries, illnesses, and
close calls/near misses
 What to do in an emergency
 Employer’s responsibilities under the program
 Workers’ rights under the OSH Act

•Provide information on job site safety and health
hazards and the controls for those hazards.
•Ensure training is provided in the language(s) and
at a literacy level that all workers can understand.
•Emphasize that the program can only work when
everyone is involved and feels comfortable
discussing concerns; making suggestions; and
reporting injuries, incidents, and hazards.
•Confirm that all employees can participate in the
health and safety program without fear of retaliation.

•Reinforce employers, managers, and supervisors’
knowledge of their responsibilities under the OSH
Act and the workers’ rights guaranteed by the Act.
•Train employers, managers, and supervisors
on procedures for responding to workers’ reports of
injuries, illnesses, and incidents, including ways to
avoid discouraging reporting.
•Instruct employers, managers, and supervisors on
fundamental concepts and techniques to recognize
hazards and methods of controlling them, including
the hierarchy of controls.

•Additional training ensures that workers incorporate
safety and health responsibilities into their daily
work routines and job activities.
•Instruct everyone on how to report occupational
injuries, illnesses, incidents, and concerns.
•Instruct everyone assigned specific roles within
the safety and health program on how to carry out
those responsibilities including:
 Hazard recognition
 Incident investigations
 Program evaluation and improvement

•Train workers on techniques to identify hazards,
such as job hazard analysis.
•Train workers to understand and recognize the
hazards they may encounter at work, as well as
more general work-related hazards.
•Instruct workers on concepts and techniques
for controlling hazards, including the hierarchy of
controls and its importance.
•Train workers on proper use of work practice and
administrative controls.
•Train workers on when to use and how to wear
required PPE.

•Provide additional training, as necessary,
when construction progresses.
•Consider situations such as when new trades
and/or equipment arrive at the job site to perform
the next phase of the project.
•Discuss the health and safety hazards and the
prescribed controls of the job site with new hires.
•Re-train workers when work practices are not being
followed or when PPE is not being is not being used
as intended to protect the worker.
•Enforce the workplace rules to ensure workers are
protected from harm.

•Control measures are periodically evaluated for
effectiveness.
•Processes are established to monitor program
performance, verify program implementation, and
identify program shortcomings and opportunities for
improvement.
•Necessary actions are taken to improve the
program and overall safety and health performance.
•Metrics are used on a platform to measure
performance improvements.
•Establish, report, track goals and targets to indicate
whether the program is making progress.
Program Evaluation
and Improvement

•Develop and track indicators of progress toward
established safety and health goals.
 Track lagging indicators: number and severity
of recordable injuries and illnesses; results of
worker exposure monitoring of hazardous
exposures; workers’ compensation data,
including claim counts, rates, and cost
 Track leading indicators: level of worker
participation in program activities; number of
hazards, near misses, and first aid cases;
number and severity of identified hazards
during inspections; number of trained workers
Program Evaluation
and Improvement

•Verify that core elements of the program have been
fully implemented on each of your job sites.
•Involve workers in all aspects of program
evaluation including: reviewing audits, surveys, and
inspection reports; incident reports and exposure
monitoring results; tracking performance indicators;
and identifying ways to improve the program.
•Verify recordable injuries and illness are reported,
job site inspections are done, hazards identified and
controls effective to reduce injury and illness.
•Correct program shortcomings and examine
potential opportunities to continually improve.
Program Evaluation
and Improvement

•General contractors, contractors, and staffing
agencies commit to providing the same level of
safety and health protection to all employees.
•All stakeholders communicate the hazards present
at the worksite and the hazards that work of contract
workers may create on site.
•General contractors establish specifications and
qualifications for contractors and staffing agencies.
•Prior to beginning work, stakeholders coordinate on
work planning and scheduling to identify and resolve
any conflicts that could impact safety or health.
Worksite Communication
and Coordination

•Effective communication and coordination among
such employers means general contractors and
their workers are aware of:
 Types of hazards from work done on-site
 Procedures or measures needed to avoid or
control exposure to these hazards
 How to contact contractor, subcontractor, or
staffing agency about health and safety issues
•Failure to communicate and take these steps may
undermine established health and safety programs.
•Inconsistent enforcement of policy and procedures
may question credibility of the employer’s program.
and Coordination

•Each general contractor establishes and
implements a procedure to ensure the exchange of
information about job site hazards and the hazard
control measures in place.
•These determinations can be included in contract
documents that define the relationships between the
parties and confirmed at pre-construction meetings.
•Each employer to assess hazards encountered by
its workers and to avoid creating hazards that affect
other workers on the site.
•Share data about injury, illness or hazard reported,
track results, and conduct trend analysis for pattern.
and Coordination

•Each general contractor collaborates on site visits
and inspections and to access injury and illness
records and other safety and health information.
•Share information on hazards that could occur as a
result of nonroutine operations or emergencies and
procedures to follow in emergency situations.
•Information is communicated before on-site work
starts and, as needed, if conditions change.
•Include health and safety information and specs in
contracts and pre-qualification bid documents.
•Resolve concerns during pre-construction meeting.
and Coordination

•Ensure that work is planned and scheduled to
minimize impacts on safety or health of workers.
•Ensure joint-employed workers are adequately
trained and equipped before arriving on worksite.
•Harmonize their safety and health policies and
procedures to resolve important differences.
•Work together to deal with unexpected staffing
needs by ensuring enough workers are trained and
equipped to protect them from harm.
•Managers with decision-making authority are
available and prepared to deal with day-to-day
coordination issues.
and Coordination

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